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T.C. Memo. 2003-267, affd. 125 Fed. Appx. 201 (9th Cir. 2005).
In the case before us, remand to Appeals for consideration of
petitioner’s tax liabilities would be neither necessary nor
productive. See Lunsford v. Commissioner, 117 T.C. 183, 189
(2001); Sapp v. Commissioner, T.C. Memo. 2006-104; Priestly v.
Commissioner, supra. Further, a remand to respondent’s Appeals
Office would, more likely than not, needlessly delay the
collection of petitioner’s tax liabilities plus related additions
to tax and interest, which, if the proper amounts have been
assessed, are already long overdue. Priestly v. Commissioner,
supra.
Upon examination of the record, we find that petitioner has
offered nothing to indicate that any adjustment to respondent’s
assessments for 1987 and 1988 is warranted. Petitioner
stipulated to the receipt of income from the multiple sources for
both taxable years at issue. Further, petitioner advanced
nothing but nebulous protests against the assessed tax
liabilities. His petition simply asserted that he “was a truck
driver in 1987-1988 and did not have the income so as to owe
these taxes.” His Form 12153 stated only that he had filed his
taxes every year, that he was not aware of the liabilities, that
he never owned a company, that he did not have any records
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